Intro: Most of what's being written about India's new export realisation rules leads with 1 October and fifteen months, and stops there. That's the wrong read if you're shipping this week. Right now, in mid-September, an order that leaves an Indian port has nine months, not fifteen, to bring its proceeds home — and that clock is fixed the moment the goods ship. It doesn't move if the rules change again before the deadline arrives. Two different realisation periods are running side by side this month, and which one applies to your shipment depends entirely on the date on the shipping bill, not the date you happen to be reading this.
The clock that's already changed twice this year
Before 14 November 2025, exporters worked to the original 2015 rule: proceeds due back within nine months of shipment. An amendment stretched that to fifteen months from 14 November 2025. Then, on 5 June 2026, the RBI reversed course — a First Amendment to the framework pulled the realisation period back down to nine months, and that nine-month window has applied to every shipment leaving India between 5 June and 30 September 2026.
The Reserve Bank's new Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 — a single rulebook replacing the old 2015 regulations and 167 separate circulars — take effect on 1 October and restore fifteen months as the standard, eighteen for exports invoiced or settled in rupees.
The back-and-forth wasn't arbitrary. The stretch to fifteen months in November 2025 was a relief measure tied to that period's US tariff disruptions, giving exporters more room while trade routes were unsettled. Reverting to nine months in June 2026 was framed by the RBI as reinforcing India's external sector position — tightening the window pulls foreign exchange back into the country faster. Both moves were real policy calls, not clerical corrections, which is exactly why treating either number as a fixed fact rather than a moving target is the mistake to avoid.
Why the shipment date decides, not the date you check
The detail that gets lost in most coverage of this: the realisation period that applies to a shipment is the one in force on the day it ships, and it stays that way for the life of that shipping bill. A parcel that left India on 10 September has nine months on the clock, full stop — due back by roughly 10 June 2027 — even though by the time most of that window has passed, the regulatory framework it shipped under will have been replaced. A shipment on or after 1 October gets fifteen months, eighteen if settled in INR, from day one.
Nobody retroactively upgrades an already-shipped order to the more generous window, and nobody downgrades one either. So the practical move this month isn't just learning the new number — it's knowing which clock is running against each batch you've already sent, separately from the one that applies going forward.
What 1 October actually resets
From 1 October, two things change together. The headline number moves back up to fifteen months for goods, counted from the date of shipment, and services, counted from the date of invoice, with eighteen months where the export is invoiced or settled in Indian rupees. And separately — this is the part that matters more for how most D2C brands actually sell abroad — the clock for goods sold out of an overseas warehouse stops running from the date of shipment at all. It starts from the date the goods are actually sold out of that warehouse.
That's the Amazon FBA, Noon, and third-party-logistics model nearly every brand testing UAE or UK demand uses, and it closes a real trap: under a shipment-dated clock, inventory that sits slow-moving in a Dubai or London warehouse could burn through its entire realisation window before a single unit sold, turning unsold stock into a compliance breach on top of a commercial one.
Turning the clock into something your bank can track
None of this runs on trust. Every shipping bill is tracked against your realisation status in the RBI's EDPMS ledger, reconciled through your authorised dealer bank, and an entry that runs past its window — whichever window applied to it — follows you and the bank until it's closed. It's the same shipping bill that carries your RoDTEP claim, worth checking both boxes are correctly filled at the same time you file rather than treating them as two separate errands.
Extensions exist, and AD banks now have more latitude to grant them, permit set-offs against import payables, or accept third-party receipts without routing every exception back through the RBI first — one of the more useful, less-discussed effects of the new regulations being principle-based rather than prescriptive. But that latitude is something you ask your bank for before a deadline lapses, not something that applies automatically.
Miss the window entirely and it isn't a quiet administrative lapse. Unrealised export proceeds are treated as a continuing offence under FEMA — the exposure accrues for every day the entry stays open, not just once at the deadline — and exporters with a pattern of overdue entries can end up on the RBI's Caution List, which affects future export transactions and banking relationships well beyond the one shipment involved. The regularisation route most exporters actually use is the Late Submission Fee scheme, a fixed-fee way to clear a late entry without going through formal compounding proceedings — available for up to three years after the original due date, which is a real safety net, but a fee-bearing one, not a substitute for tracking the deadline in the first place.
The difference a shipping date makes is concrete, not abstract — here's the same kind of order, shipped a few weeks apart under the two rules running this month:
| Ship date | Realisation period | Proceeds due by |
|---|---|---|
| 14 September 2026 | 9 months (interim rule, in force through 30 Sept) | ~14 June 2027 |
| 5 October 2026, invoiced in USD | 15 months | ~5 January 2028 |
| 5 October 2026, invoiced/settled in INR | 18 months | ~5 April 2028 |
| Amazon FBA / Noon / 3PL stock, shipped any date from 1 Oct | 15 months from date of sale, not shipment | 15 months after the unit actually sells |
Waiting three weeks to ship the same order buys six extra months on the clock — and for anything routed through an overseas warehouse, the clock doesn't even start until the unit sells.
If you have orders sitting in transit right now, the practical question isn't which rule is fairer — it's which one already applies to what you've shipped. Anything that left before 5 June is still tracked against the fifteen-month window that was in force then. Anything shipped between 5 June and 30 September sits on the nine-month interim clock, which for the earliest of those shipments starts coming due as soon as March 2027. And anything you're about to ship in the next two and a half weeks is the last batch to fall under the interim rule at all — one more reason the date on the shipping bill, not the date on the calendar when someone reads this, is the only number that matters for a given order.
Worth doing before you ship next
- Check the ship date, not today's date. Anything that left India before 1 October is running on the 9-month interim rule regardless of when you happen to read this.
- Work out which clock applies to your model. A direct sale and stock sold from an overseas warehouse now start on genuinely different days, and getting that wrong throws off your whole tracking sheet.
- Talk to your AD bank about the new latitude on extensions and set-offs before you need it, not after an entry is already overdue.
- Reconcile open EDPMS entries now, especially anything shipped in the 5 June–30 September window that's closer to nine months old than it looks.
- If something's already overdue, look at the Late Submission Fee route before compounding. It's a fixed, known cost to regularise a late entry, and it's available for up to three years after the original due date — worth using before a pattern of overdue entries puts you anywhere near the Caution List.
The rule that governs your shipment is the one in force the day it left the port — not the one in force the day you're reading about it.
None of this is a reason to slow down shipping while the rules settle — the bigger risk is a brand that assumes the newest headline number covers everything already on the water, when the entry sitting in EDPMS from three weeks ago is actually running against the old clock. We handle local banking and INR repatriation as part of onboarding, on both the AED and GBP side of the settlement stack, so the brands we take cross-border are closing entries against the deadline that actually applies to each shipment, not the one that sounds current.